Diana, Sherri A. (CDC/NIOSH/EID) (CTR) 

From: Tami Thatcher 

Sent: Wednesday, December 02, 2015 2:27 PM 

To: NIOSH Docket Office (CDC) 

Subject: Concerns about NIOSH analysis concerning the Idaho National Laboratory radiation doses 

DearNIOSH, 

Following up on last year's NIOSH interviews with current and former Idaho National Laboratory employees 

regarding radiation exposure estimation I would like to emphasize again that the conflict ofinterest involving 

the fact that Department ofEnergy contractors who often were at fault for causing excessive exposures, and will 

be fined or have award-fees reduced due to excessive radiation exposures are in charge ofthe processes to 

estimate the radiation exposure. There has been more than one instance the I know of personally that involves 

INL contractors being less than forthcoming about the radiation exposure of workers, especially when the 

contractor is at fault for the exposure. Thus, the highest radiation doses received may not be acknowledged and 

existing documentation ofthe dose may not sufficiently allow NIOSH to estimate the actual dose a worker 

received. 

This conflict ofinterest is coupled with the practice ofwithholding radiation dose estimation reports from the 

exposed employees. While an employee is provided when an annual total dose summary, an employee seeking 

information about how his or her internal dose was estimated must conduct a Freedom of Information Act 

request. This request is often initially denied for no justifiable reason, thus requiring the additional effort and 

time of an appeal. The time delays this involves come to many weeks, and this is only after the weeks or months 

that the contractor may take in order to prepare the radiation dose estimate. How does the exposed worker get 

competent an<l timely medical assistance when they do not have identification of the radionuclides and amounts 

taken in to the body? And worse, the employee may be branded a trouble maker simply for requesting the more 

detailed information about their radiation exposure. The level of conservatism in contractor radiation dose 

estimates is widely variable and without knowing what assumptions were made in the assessment as well as 

bioassay trending, a worker lacks sufficient information about the characterization oftheir dose. For example, 

contractors are not required to consider solubility class super S for plutonium exposures, even decades after the 

Department of Energy has found plutonium lung clearance can be much slower than assumed in officially 

recognized dose estimation models. Thus, lung dose for workers inhaling plutonium may be much higher than 

official dose estimates yield. While it is commendable that NIOSH does not rely on the contractor's dose 

estimates and NIOSH will conduct an analysis that can include more accurate assumptions regarding such 

things as solubility class, Super S for highly insoluble plutonium, NIOSH is still going to be reliant on 

contractor information about the exposure. 

As I found no record ofNIOSH having grasped these facts from several interviews that I attended or directly 

participated in, I want to state on the NIOSH website that the conflict ofinterest issue works against radiation 

workers and may result in underestimation ofradiation dose for workers, especially those workers involved in 

any kind ofmishap at the Idaho National Laboratory. The supposed NIOSH reviews of contractor radiation 

record programs and dose reconstruction appear to not factor in the intentional act ofunderreporting radiation 

doses. 

I would like to also mention the fact that individuals interviewed by NIOSH have their comments recorded in a 

way that I can only describe as haphazard and with a bias toward a deaf ear to anything negative about 

Department ofEnergy contractors. And the comments provided by individuals to NIOSH are subsequently 

provided to the Department ofEnergy and its contractors with full identification ofthe person giving the 

comments. Thus, a current employee can expect retaliation for providing any information that can be deemed 
unflattering to the Department of Energy or its contractors. Does this sound like the best way to really 

investigate any problems at DOE contractor's sites? 

On the issue I raised to NIOSH concerning drinking water contamination at the Idaho National Laboratory, 

there was no meaningful response by NIOSH that I could perceive and a pervasive tendency to repeat that the 

Idaho Snake River Plain Aquifer is clean - just read the latest website information about it. There are two 

problems with this: measurements off the Idaho site have no bearing on measurements at the Idaho site's 

facilities. And measurements today at the Idaho site do not reflect what INL workers at various locations were 

ingesting in earlier decades. 

The analysis necessary to estimate the levels ofradioactive and chemical contaminants in INL drinking water 

based on intermittent and often decades-tardy monitoring, for each drinking water well and for each year of 

operation has not been performed. While various documents have some years ofmonitoring data, most decades 

of INL operation do not have complete monitoring or hindsight derivation ofwhat the contamination levels 

were. I have compiled some highlights of drinking water contamination at the Idaho National Laboratory in a 

report, "The Hidden Truth About INL Drinking Water"available at http://environmental-defenseinstitute.orvpublications/IN LdrinkwaterR I .pdf 

The Energy Employee Occupational Illness Compensation law addresses both chemical and radiological 

exposure. However, it is an unfortunate fact that NIOSH does not consider the damage caused by simultaneous 

exposure to both chemical and radiological contamination. But not having the legal requirement to consider 

both effects does not alleviate the increased damage to health, nor what should be learned about the exposure of 

workers to both chemicals and radiation. The failure to characterize, for each year of INL operation, the level of 

chemical contamination and radiological contamination in INL drinking water, as can be derived from plume 

migration and later monitoring results is a serious flaw in INL site characterization as well as NIOSH 

epidemiology efforts that NIOSH should have had the technical ability to identify. But NIOSH not only did not 

identify this problem, they seem unreceptive to acknowledging the need for a forensic analysis, so-to-speak, of 

past INL drinking water contamination levels. 

I also want to point out how unfortunate it is that NIOSH chose not to present the bulk ofldaho National 

Laboratory related ongoing investigations when the NIOSH board met in Idaho in July 2015. Why would the 

board choose to conduct its meeting in a way that omitted the most important and !NL-relevant presentation 

while former INL workers were in attendance? It is also extremely saddening to see the way that NIOSH 

meetings give public comment opportunities and yet these comments again and again appear to fall on very 

intentionally deaf ears, whether those of the NIOSH staff or ofthe oversight board. It is the image of 

transparency but not actual transparency (i.e., choosing not to provide presentations on INL at the Idaho Falls 

meeting) that matters most to NIOSH. It is the image of caring what workers and the public think but not 

actually caring as evidenced by lack of comprehension and lack of action. It is the image of a highly technical 

and scientific process that matters most to NIOSH and an absence of clarification of where existing approaches 

are likely to be inadequate. 

The image ofthe Wizard of Oz, providing a pageant, smoke and mirrors all intended to mesmerize the audience 

comes to mind as I watch NIOSH explain how it performs radiation dose reconstruction. NIOSH seems to use 

technically incomprehensive jargon-filled discussions to disenfranchise former workers and family members. 

Communication with more clarity would no doubt lead to anger and disgust at past and continuing Department 

ofEnergy practices. 

It is encouraging that NIOSH is investigating the recent petition regarding historical radiation doses at INL, 

Petition 219. Without that petition, many ofthe recent discoveries ofinadequate radiation protection of INL 

would not have occurred. NIOSH and its contractors are to be commended on the ongoing investigations that 

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have found sufficient evidence for establishing radiation cohorts for workers than would not have an adequately 

monitored and recorded dose. 

NIOSH, despite the name: ''National Institute of Occupational Safety and Health" appears to take no interest in 

the health of current employees as evidenced by the refusal to identify what jobs and what INL sites have had 

and continue to have radiation illness claims. It would not be that difficult to do, yet because it could cost the 

Department of Energy money to clean up its act at various facilities, it isn't being done. Did workers who 

change contaminated air filters have adequate protection? Or pipe fitters working to repair pumps and valves in 

radioactive systems? Or workers using bulldozers to move contaminated soil? Or workers in depleted uranium 

processes? Workers drinking contaminated water for decades? NIOSH chooses not to be able to answer these 

questions. 

In reviewing the November 10, 2015 presentation regarding the Idaho National Laboratory's Test Reactor Area, 

"INL Test Rector Area Nuclear Modeling," a presentation give in Ohio and not in Idaho, I find the presentation 

raising many questions regarding the estimation ofunmonitored fission products. The presentation characterizes 

the reactor fuel used in reactor's there but makes no mention ofthe many experiment fuels and experiment 

materials, often destructively examined both in reactor facilities and laboratory facilities at TRA. The 

shortcomings would not be apparent to anyone in Ohio. 

As I have witnessed very incorrect and incomplete understanding of various issues at INL expressed by NIOSH 

personnel such as "all the plutonium at INL is safely bound up in reactor fuel" when plutonium has been and 

continues to be emitted by various INL facilities as evidenced in site environmental monitoring reports. 

Plutonium and other radionuclides have been blowing in the wind from disposal and subsequent flooding of the 

disposal site at the Radioactive Waste Management Complex. Airborne releases ofplutonium from RWMC's 

cleanup efforts have been high, even with supposed air filtering. Thus, I have heard with my own ears placating 

falsehoods spoken by supposed NIOSH INL experts, so I have come to not trust the completeness of 

understanding ofNIOSH experts trying to comprehend the enormous variety and complexity of operations at 

the Idaho National Laboratory. Given the historical shortcomings ofNIOSH's ability to grasp the operations at 

INL, NIOSH should be making an effort to get feedback from INL workers. Withholding INL presentations 

while in Idaho and giving INL presentations while in Ohio isn't really an excellent way to proceed. 

I appreciate the difficult technical challenge that radiation dose reconstruction at INL entails. I appreciate that 

progress that has recently been made in investigating the INL Petition 219. But I wish to caution former 

workers and NIOSH about the longstanding tendency ofNIOSH to avoid seeing, hearing, acknowledging or 

acting in any way that might cast a negative view on nuclear radiation and Department of Energy operations. 

And I will close with this suggestion. Before I hear one more time from one more NIOSH person how "people 

get cancer - radiation doesn't cause cancer" or something to that effect, I suggest that these highly educated 

NIOSH people so sure that radiation doesn't cause cancer and so eager to informally inform people at NIOSH 

events ofthis fact read the latest epidemiology study for occupational exposure to ionizing radiation by 

Richardson published in 2015. [Richardson, David B., et al., "Risk of cancer from occupational exposure to 

ionizing radiation: retrospective cohort study ofworkers in France, the United Kingdom, and the United States 

(INWORKS), BMJ, v. 351(October 15, 2015), at http://www.bmj.com/content/35 1/bmj.h5359 Richardson et al 

2015 ] (And please note that studies ofhigh leukemia risk in radiation workers and of ongoing studies to assess 

health effects of high and low-linear energy transfer internal radiation must also be studied in addition to this 

one on external radiation.) 

Thank you. 

Sincerely, 

Tami Thatcher 

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